The CFTC guidance provides that a futures commission merchant (FCM), swap dealer (SD), or introducing broker (IB) that receives separate compensation for commodity trading advice is not required to register as a commodity trading advisor, provided that the offered advice is “solely incidental” to the conduct of the FCM’s or SD’s business, or “solely in connection with” the operation of the IB’s business.

The interpretation was requested as a result of the EU’s Markets in Financial Instruments Directive II (MiFID II Directive), which will require certain investment managers to...

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